Corporate Compliance

Tip: Report non-compliance promptly

Compliance Monitor, July 1, 2009

If the compliance officer or committee discovers evidence of misconduct or noncompliance and has reason to believe that the misconduct may violate criminal, civil, or administrative law, the discoverer should report the existence of misconduct to the appropriate governmental authority within a reasonable time period. It is recommended that such reports be made within 60 days after determining that a violation occured.

Prompt reporting is important because it demonstrates the hospital’s good faith and willingness to work with governmental authorities to correct and remedy and compliance problems. More importantly, if the reporting provider becomes the target of an investigation, reporting such conduct will be considered a mitigating factor by the OIG and DOJ in determining administrative sanctions such as penalties, assessments, and exclusion.

This tip was adapted from The Compliance Officer’s Handbook, Second Edition. For more information about the book or to order your copy, visit the HCMarketplace.

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